Background

CarteNav Solutions Inc. is a growing enterprise located in Halifax , Nova Scotia , Canada . CarteNav develops software and hardware solutions for maritime surveillance and security, mobile asset tracking and telematics in the airborne, surface and underwater domains. We specialize in the development of application-specific, user interfaces that enable effective data collection and visualization on hardware platforms varying from handheld to desktop. Our client software is operating system independent which allows flexibility in how it can be deployed. We specialize in solutions that combine the collection, communication, storage and visualization of position-annotated data acquired from sensors or human-machine interfaces.

Purpose of this Policy

This Policy describes the way that CarteNav collects, uses, retains, safeguards, discloses and disposes of the personal information of customers and others.

This Policy describes the way that CarteNav will, subject to applicable legal requirements, adhere to all relevant federal and provincial legislative privacy requirements. The Policy follows the 10 Canadian Standards Association ( CSA ) principles identified in the federal Personal Information Protection and Electronic Documents Act (PIPEDA). The Policy describes each principle and the method of implementing each. CarteNav will strive to meet or exceed federal and provincial legislative requirements and will ensure that it remains current with changing technologies and laws. Any and all changes will immediately be posted to the CarteNav Solutions Inc. web site.

1. Accountability

1.1 CarteNav will appoint a staff person (the "Privacy Officer") whose responsibilities will include those of the implementation and monitoring of the CarteNav Solutions Inc. Privacy Policy. The Privacy Officer will be responsible for CarteNav's compliance with privacy principles. This person will also be responsible for responding to access requests in accordance with this Policy. The Privacy Officer will report to the President and the ultimate responsibility for Privacy issues will rest with the CarteNav Board of Directors. The Privacy Officer may at his/her discretion enlist assistance from other staff members and/or volunteers within the organization. This will not in any manner mitigate his/her responsibility for Privacy issues.

1.2 CarteNav's Privacy Officer will ensure that CarteNav manages all personal information in its possession in accordance with this Policy including that which may be transferred to a third party. Third party organizations who handle information on behalf of CarteNav shall be contractually obligated to adhere to the standards of CarteNav Solutions Inc.

1.3 CarteNav will implement internal policies which will facilitate adherence to this Privacy Policy including but not limited to the following:

Security measures at all levels designed to protect personal information in our possession.
• Implementing procedures designed to respond to complaints and/or inquiries.
• Staff training in all facets of information management, including awareness of CarteNav Solutions Inc. Privacy Policy and policies and procedures developed in accordance with the Policy.

2. Identifying Purposes, Type of Information Collected and Website

2.1 CarteNav Solutions Inc. shall only collect the information reasonably necessary to conduct CarteNav activities. Access to our Privacy Policies and procedures will be readily available. Similarly, the process by which challenges may be made to CarteNav's compliance and/or adherence to the legislation in question shall be readily available and transparent.

2.2 CarteNav may collect personal information from customers, affiliates and partners for the purposes of conducting CarteNav activities. Specifically:
• Information concerning feedback on products and services is collected to measure the success of our company in order that we may better plan future endeavours.
• E-mail addresses may be collected for the purposes of updating new consumers and engaging prospective customers.
• Potential and actual insurance claims and the subsequent investigation thereof.
• Appeals and regulations challenges as well as information collected to defend CarteNav against legal action brought against CarteNav.

2.3 CarteNav will endeavour to ensure that all collectors of the personal information are familiar with the potential use of the personal data. All personal data collected by CarteNav shall be maintained in the main office which is listed on our web site.

2.4 CarteNav Solutions Inc. will request individually permission for the use of any personal data collected which is extraneous to that which has been identified above, unless said usage is authorized by law.

2.5 CarteNav may also use information about an individual who accesses secure areas of www.cartenav.com. It is always your choice to provide information in certain fields although failure to complete certain sections may inhibit your ability to fully access all areas of the web site. Our web site also collects non-identifiable information about users such as the users IP address, the sections of the web site visited and the information downloaded. CarteNav may use this non-identifiable information and disclose it to service providers, for system administration purposes and to improve the web site.

3. Consent

3.1 CarteNav Solutions Inc. will use the personal information for the uses specified above in section 2 and in Sections 3.2 below. By consenting to provide your information to CarteNav, you are deemed to consent to our use of the information for the purposes of CarteNav activities listed in Section 2 of this Privacy Policy and to disclosure of the information to other associated organizations for the same purpose.

3.2 CarteNav may collect personal information without consent where reasonable to do so and where permitted by law.

4. Limiting Collection

4.1 All information shall be collected fairly and lawfully within the criteria as set forth in our Privacy Policy.

4.2 CarteNav shall not indiscriminately collect information. The amount and type of information we collect shall be limited to that which is required to fullfill our identified purposes.

4.3 CarteNav will not use any form of deception in gaining personal information from its members.

5. Limiting Use, Disclosure and Retention

5.1 Subject to applicable legislation, CarteNav shall limit use of personal information it collects to purposes that we have disclosed in Sections 2 (Identifying Purposes) and 3.2, Consent.

5.2 CarteNav Solutions Inc. shall maintain documents for certain periods of time dependant upon necessity. More specifically:
• CarteNav may from time to time enlist the services of third party vendors in order to provide CarteNav products, technical and support services. Prior to enlisting the services of these firms we will contractually commit them to treat your personal information consistent with the Privacy Policy of CarteNav.
• CarteNav may at some point be involved in the sale, merger, transfer or reorganization of its activities. We may disclose personal information to the other party in such a transaction. CarteNav will ensure that we contractually obligate the other party to treat this information in a manner consistent with our Privacy Policy.
• CarteNav may disclose your personal information to a government authority that has asserted its lawful authority to obtain the information or where the association has reasonable grounds to believe the information could be useful in the investigation of an unlawful activity, or to comply with a subpoena or warrant or an order made by the court, person, or body with jurisdiction to compel the production of the information or otherwise as permitted by applicable law.
• CarteNav may at its discretion release personal information for the purposes of collecting debts which may be owed to CarteNav Solutions Inc.

5.3 Certain documents may be subject to legislated retention periods either federally or provincially and these will be respected at all times by CarteNav.

6. Accuracy

6.1 CarteNav shall strive to ensure to the extent it can that the information entrusted to us is maintained in an accurate manner. We shall try to maintain the interests of the individual and attempt to ensure that decisions are not made for or about an individual based on personal information that is flawed.

7. Safeguards

7.1 Security safeguards have been implemented to ensure your personal information is protected from theft as well as unauthorized access, disclosure, copying, use or modification thereof.

7.2 The level of safeguards employed shall be directly related to the level of sensitivity of the personal information collected. The more sensitive the information, the higher the level of security employed.

7.3 Methods of protection and safeguards to be employed shall include but in no way be necessarily limited to locked files, offices and storage areas, security clearances and need to know access as well as technological measures such as passwords and encryption.

8. Openess

8.1 CarteNav publicly discloses the methods by which we handle your personal information. This information is readily available through our Privacy Policy, on our web site or upon request by contacting the CarteNav Privacy Officer.

8.2 The information available includes:
• The name address and phone number of the CarteNav Privacy Officer.
• A description of the type of personal information held by CarteNav Solutions Inc. and our general uses thereof.

9. Individual Access

9.1 Subject to applicable legislation, upon request by the individual concerned CarteNav Solutions Inc. shall disclose whether or not it actually holds personal information on an individual. We shall disclose the source of this information when requested and provide an account of third parties to whom the information may have been disclosed.

9.2 CarteNav may request sufficient information to confirm your identity before releasing your personal information to you.

9.3 Subject to applicable legislation, CarteNav shall endeavour to provide this information within 30 days of receipt of the information requested and only charge nominal fees for the purpose of off-setting its expenses incurred in supplying the requested information. This information shall be provided in an understandable format, at the time you make a request.

9.4 Any inaccurate information that is brought to our attention shall be corrected by CarteNav as quickly as possible and any pertinent third parties shall be apprised of the corrections in due course.

10. Challenging Compliance

10.1 CarteNav has in place procedures for the resolution of grievances in the administration of its Privacy Policy.

10.2 Upon receipt of a complaint CarteNav shall make available the complaint procedures which will be simple and easy to access.

10.3 CarteNav shall investigate all complaints. If the complaint is deemed justified CarteNav shall take the appropriate steps to ensure that compliance is achieved and will make changes to its policies to allow for compliance in the future.

10.4 All complaints should be addressed to the CarteNav Privacy Officer.